2015 Starts Now for the Grants Community

Update your regulation bookmarks. Since the Uniform Guidancecombines and replaces the eight existing regulations into one, you will want to make sure that you have both handy. You should bookmark any agency’s “adopted and amended” at eCFR.gov as well.

Understand that it’s not just the rules.During their October 2 webcast, OMB representatives emphasized that the FAQs available on the COFAR website (and to be released as Appendix XI to Part 200 – Compliance Supplement) provide context to the Uniform Guidance.

Identify and implement the adjustments you need to make to comply with 2 CFR 200.With 60+ grants management changes, you’ll need to review your programs, policies, processes, and systems to make sure you’re in compliance. This could be as simple as a Federal program manager coordinating the public release of awards greater than $25,000 on USAspending.gov. Or, it could be developing an understanding of how and when to renegotiate your organization’s Indirect Cost Rate.

Map out when each part of the Uniform Guidance takes effect for your entity, by award. Given that the grants community has been driving towards December 26, 2014, as “the day,” it’s easy to think that everything changes in one fell swoop. Take a look at the December 15 post on some of the nuances, like deadlines for audit requirements and updated non-federal entity procurement policies. Then make sure those within your organization concur with the timeline, and that it’s documented. Remember that Federal grants officers and program managers often manage large grant award portfolios. Taking this small step can make sure your award is monitored and audited according to the “right” timeline.

Keep up-to-date on DATA Act implementation. Issuing the Uniform Guidance is just one part of grants reform. Additional changes are coming with the Federal Government’s implementation of the DATA Act during the next three to five years. As with 2 CFR 200, your organization will likely need to make changes as the Federal Government releases and implements new requirements.